This website provides information on how Atos runs its business,
extracts from the Contract between the DWP and Atos including the
MEDICAL CONDITIONS
that mean a face to face medical assessment is not always necessary,
ASSESSMENTS AND POINTS,
the breaches of Contract that occurred in my case, my unsound medical report
and the correspondence showing how difficult it is to obtain justice or advice.

Unum (previously UnumProvident) and Business

An overview of the business operations of Unum (previously UnumProvident) and
and how Unum has influenced UK Government policy through the Department
for Work and Pensions (DWP) to the detriment of the disabled.
The Unum UK website is www.unum.co.uk.
Unum has set up a website to sell to employers
www.backupplan.com.

Topics include statements made by Unum to the UK Parliament's
Work and Pensions Select Committee, financial information and supporters,
of the Unum "non-medical" model for dealing with medical conditions.

The supporters include Professor Mansel Aylward (previous DWP Chief Medical
Officer who left the DWP to direct Cardiff University's UnumProvident
Centre for Psychosocial and Disability Research, Dame Carole Black, Lord Freud
and Lord Lord Kirkwood of Kirkhope (Chairman of the Unum Customer Advisory Panel
when Chair of the UK Parliament's Work and Pensions Select Committee).

If there is a direct relationship between Unum and Atos, its nature is unknown.
Unum and Atos were part of the DWP Technical Working Groups that defined the
details of the "non-medical" model assessments that were mandatory if a person with
a disability was to be eligible to receive benefits.
The same private equity funds have interests in both Unum and Atos.
Private equity fund managers are not slow to drive companies to maximise profits.

Menu

Introduction

In July 2008, the
American Association for Justice
(www.justice.org) published a document
"The Ten Worst Insurance Companies In America:
How They Raise Premiums, Deny Claims,
and Refuse Insurance to Those Who Need It Most".
Allstate was the worst and Unum was the second worst.

Allstate's confrontational attitude towards its own policyholders
was the brain child of consulting giant McKinsey and Company in the mid-1990s.
McKinsey was tasked with developing a way to boost Allstate's bottom line.

McKinsey recommended Allstate focus on reducing the amount of
money it paid in claims, whether or not they were valid.
When it adopted these recommendations, Allstate made a
deliberate decision to start putting profits over policyholders.

The company essentially uses a combination of lowball
offers and hardball litigation. When policyholders file a
claim, they are often offered an unjustifiably low payment
for their injuries, generated by Allstate using secretive
claim-evaluation software called Colossus. Those that
accept the lowballed settlements are treated with "good
hands" but may be left with less money than they need to
cover medical bills and lost wages. Those that do not settle
frequently get the "boxing gloves": an aggressive litigation
strategy that aims to deny the claim at any cost.

Former Allstate employees call it the "three Ds": deny,
delay, and defend. One particular powerpoint slide
McKinsey prepared for Allstate featured an alligator and
the caption "sit and wait" - emphasizing that delaying
claims will increase the likelihood that the claimant gives up.

According to former Allstate agent Shannon Kmatz,
this would make claims "so expensive and so timeconsuming
that lawyers would start refusing to help
clients."

Former Allstate adjusters say they were rewarded for
keeping claims payments low, even if they had to deceive
their customers.

McKinsey and Company are important Government and DWP advisors.
McKinsey and Company represent the interests of major corporate clients.
Most companies usually meet underlings but McKinsey and Company
are so important that they meet Ministers and Chief Executives.

In January 2012, the Cabinet Office announced the appointment of
Tim Kelsey as the new executive director for transparency and open data
within the Efficiency and Reform Group (ERG) with immediate effect.
For the previous six months Kelsey has been leading on transparency in the
ERG on secondment from consultancy firm McKinsey & Co.

In November 2010, McKinsey and Company provided hospitality
in the form of a dinner for Terry Moran, DWP Chief Executive, Pension,
Disability and Carers Service (to 30 November) Director General,
Universal Credit (from 1 December).

In May 2009, McKinsey and Company were appointed
as a supplier to the DWP Cipher Consultancy Services Framework.
The Cipher agreement will cost the DWP £500 million and will
last four years.

Consider the second (2) point, if the McKinsey & Co. recommendation
to Allstate are followed by the DWP (in line with the NAO recommendation):
The DWP should focus on reducing the money the DWP pays out in benefits
irrespective of whether the claim of the claimant is valid or not.
Adding complexity and delaying payment helps the DWP to reduce the money paid out.
Formal and informal consultations, independent inquires and name changes
such as DLA to PIP, which deliver nothing of substance to claimants,
are all delaying tactics deployed to reduce benefits paid.
The influence of influential group such as cancer patients needs to be purchased.
If cancer patients were "appeased", treated as a special case if you will,
perhaps fewer cancer patients would fight for the dying, the sick,
the disabled and their carers.
Cancer patients have been offered immediate eligibility for the Support Group.
Cancer is listed in a medical category along with a number of other
equally serious medical conditions.
None of these equally serious medical conditions has been
offered immediate eligibility for the Support Group.

Consider the third (3) point, focus on units that can best afford to cut.
The DWP requires Atos to undertake ten or more assessments per day,
Health assessors are wrong target for benefit protests
(www.prospect.org.uk/news/id/2011/01223) by Prospect national secretary Geraldine O'Connell
news release 11 May 2011.
My assessment, brain tumour, lasted one hour and fifty minutes.
Atos are required to carry out ten assessments per day.
It is believed this number is far higher than previous.
If the DWP required Atos to carry out 12 or more assessments per day,
further savings pushing towards 20% could be achieved.

Consider the fourth (4) point, change the strategy:
The DWP strategy was to provide the best service to claimants.
This is not compatible with a 20% budget cut.
The DWP new strategy is to provide as poor as possible a service
to most claimants, so that budget cuts are achieved year after year.
The DWP can always claim that they have listened and
helped the cancer patients.
Thus the DWP hopes a potential very vocal media threat has been nullified.
Cancer patients are as now in the Support Group thus this "concession" is
worthless in financial terms to the patient.
If it were the case that cancer patients receive more, it follows other
patients will receive less.
The 20% budget cut will be achieved regardless. This is easier once
the largest most vocal, most organised group (cancer patients) are stiffled.
Cancer patients enjoy very high awareness, empathy and sympathy across
all demographics and this is especially the case in all voter groups.
Lord Freud in future years will add Welfare Reform to his list of pups
(EuroDisney, EuroTunnel et al) that he can brag about when he is
happy to look back and laugh at how easy it was for him to repeatedly sell
"pigs in pokes" to a gullible public.
Lord Freud, a man of no consequence, is yet another small time snake oil
salesman that history will quickly forgets.

It is believed that Unum learned from McKinsey and Company.
and have created the "non-medical" approach to medical
condition assessment because their forward projections of liabilities as a result
of disability insurance previously written would vastly exceed past, current and
future premium income. The financial forecast was so dire that minor changes such
as time limiting payments, increasing premiums greatly with age and denying
disability insurance to many groups (only sell to the employed through their employers)
would not be sufficient to bridge the growing gap between premium income and outgoings.
It was the "medical" aspect of the disability insurance that was the problem that needed
to be addressed. This was solved at a stroke (no pun intended) by claiming a "non-medical"
model should be used.

Research centres and certification of healthcare professionals, funded by Unum
and those such as Atos who apply the Unum "non-medical" model, was
and is expected to give the "non-medical" approach credence and legitimacy.
The medical profession consider rightly that "non-medical" models are outside
their remit.

E pluribus Unum
James Purnell's reforms of incapacity benefit are inspired by a US company
with vested interests and a murky record. Now, that's really sick

By Jonathan Rutherford, Guardian, 17 March 2008

...Unum has built up its influence in Britain. In July 2004, it opened its
£1.6m Unum Centre for Psychosocial and Disability Research at Cardiff
University. The company appointed Mansel Aylward as director following his
retirement from the DWP in April. The launch event was attended by Archie Kirkwood,
recently appointed chair of the House of Commons select committee on work and
pensions. Malcolm Wicks, minister of state in the DWP, gave a speech praising
the partnership between industry and the university.

The aim of the centre is to transform the ideology of welfare and so help
develop the market for Unum's products. In 2005, the centre produced a monograph
The Scientific & Conceptual Basis of Incapacity Benefits (TSO, 2005) written
by Aylward and his colleague Gordon Waddell. It provides the framework for the
2006 welfare reform bill.
Its methodology is the same one that informs the work of Unum...

Governments throughout the world faced similar challenges; aging population,
increase in the number of working age people with disabilities and lower tax revenues.
Unum are key drivers in "health care" insurance associations though which influence
on senior Government officials is applied.

The Unum "non-medical" approach, if given credence by Governments, can be
easily sold to employers, who face similar challenges to those of Governments.

Unum is wary to undertake the "non-medical" assessments for Governments
directly. Unum prefers companies like Atos, a software company relatively new
to disability assessments, to undertake the assessments and take the criticism.

Unum prefers to sell to employers who bundle their Unum disability insurance
including the "non-medical" assessment as another "benefit" to employees.
UK contracts of employment are usually confidential.
An employee loses benefits after changing employer.
Most disabilities arise years after premiums have been paid and little
attention is paid when the insurance is written that a "non-medical" assessment
will decide eligibility for payment and that the assessment is wholly
dependent on Unum policy at the time.
In the UK, the widespread criticism of "Atos" assessments is beneficial
to Unum as it undermines confidence in the state provision of disability benefits.
Loss of confidence makes it easier to sell to employers.

The training that Unum provided to their "financial advisor" sales people
has been published.
It was produced by Unum so that Unum can undermine the confidence
of their UK target market in the Welfare State and so sell their
discredited insurance.
http://blacktrianglecampaign.org/2011/09/15/unums-game-plan/

Presentation points:

The Claimants progress will be regularly assessed and interviews will be conducted
by a third party contractor paid on results.

Even the highest rate of benefits will fail significantly short of what most
clients need in order to meet their usual household bills.

But a significant shortfall continues to exist between state benefit levels
and usual levels of household spending, offering a significant
opportunity for advice.

Unum do not publish a list of employers who provide Unum insurance
to their employees. Unum operate with many names which makes
independent research difficult but not impossible.

"A fool and his money is soon parted" seems to me to be an accurate
reflection of how Unum will keep premium income greater than outgoings
now and into the future.

Unum Product

Unum described their offering in a news release as follows.
It is hard to find details of how the Unum "non medical" model
for assessing medical conditions is applied and how this relates
to denials of claims.

Unum's new Income Protection option offers a back up plan for all

Foundation level cover provides protection for essential financial outgoings should
people be unable to work due to illness or injury

Unum is introducing a new foundation level of Income Protection cover, designed to
support the nine out of ten UK employees who do not currently have a financial back up
plan in place against long term illness or injury.
This is intended to relieve the financial burden and stress from an employee and
ensure that their essential outgoings, such as mortgage payments, bills and transport
costs, can be paid whilst they recover.

Classic Group Income Protection is rich in benefits and offers the best cover available
to people on long-term sick leave. However, employers tend to offer it only to their
most senior employees. The new foundation level of Income Protection will offer robust
cover - up to 60% replacement income with no offset for State benefits - at a
lower cost, helping employers to offer everyone in the work place a back up plan.

Unlike other products in the market which stop payment to everybody after a short period
of 2 - 5 years, this foundation cover will continue to pay until retirement for those
who need it the most - the 30%-35% of our claimants that cannot perform any
suited activity and will never return to work. Exposure to Unum's market leading
rehabilitation programme will ensure that the majority can return to their own
occupation within two years.

Tom Dupuis, Head of Products at Unum UK, says: "In the current economic climate,
employees value their benefits package far beyond its short-term monetary value.
Income Protection provided through the work place extends the financial security
of employees, meaning they have a back up plan in place if they are unable to work
due to illness or injury.

"Employers tell us that cost is often a barrier to offering Income Protection to all
staff, so we've developed a low cost option, which is still tax deductible.
Budget conscious employers can now cover their entire work force, allowing employees
to protect their essential outgoings and have access to professional and financial
assistance to facilitate a return to work."

For as little as £200 per year per employee, employers will be able to extend
Income Protection to entire work forces, rather than solely their senior executives,
where cover has historically resided.

As part of the new option, businesses can expect:

A replacement income for employees to help them pay for their essential outgoings
whilst they recover from a long illness or serious injury.
If required, Unum will support the most incapacitated employees with a replacement
income all the way through to Policy Terminal Age (e.g. State Pension Age/age 65)
when an alternative income (e.g. pension) may become available.

Confidence that employers will receive the support they need to help their employees
return to work when or if possible.

Employees paid direct. Should an employee be unable to return to work and the
employment relationship has to cease, Unum will pay the replacement income direct,
allowing both parties to move on once any Duty of Care obligations have been met.

Easy administration that complements existing procedures and sick pay arrangements,
providing absence management support to employers and their business every day
(not just when needing to make a claim).

An affordable and flexible employee benefit for employers who may have thought
they could never afford Income Protection for their entire work force.
An option that fits an employer's budget and their staff's needs - and a foundation
to build on in the future.

This new cover option ties into Unum's press campaign to educate employers and
employees about Income Protection. The campaign, which launched earlier this year,
is geared towards raising awareness of the risks employers and employees face
without a back up plan in place, and to explain what Income Protection is.
The new foundation cover will support Unum's aim to make Income Protection more
accessible to the entire UK work force.

Unum's education campaign is running on TV, in newspapers and online through social media.

http://www.unum.co.uk/about-us/news-releases/archive/...

Unum have withdrawn from selling direct to individuals.
I think that says it all.
Most reasonable people would some up the situation as:
"If you can't take the heat, quit the kitchen and send in someone else
to take the heat".

Unum Performance

The lack of merit of the Unum income protection insurance is
supported by the numerous cases of Unum declining insurance claims.
Unum have stated to Parliament that they support a "non-medical" model
for the assessment of medical conditions.
Even more disturbing is the following.

Disability Insurer Found Guilty of Social Security Fraud
by Mary Williams Walsh published 23 October 2008 by the New York Times

A federal jury in Boston found that Unum, the nation's largest disability
insurer, had committed fraud in some cases by requiring customers to apply for
Social Security benefits even though it knew they were not eligible.

Unum do publish statutory financial information but detailed
searches of Unum published information do not reveal statistics on
the claims approved, the claims declined and the medical conditions
of the claimant.
A reasonable person might conclude that if a "non-medical" model for
assessment is followed, the medical condition of the claimant
is not relevant. This person might further conclude that the
assessor does not need medical qualifications to carry out an assessment.
This seems to contradict the claims made in January 2012 by
Unum (www.backupplan.com)
on the front page of Unum's BackUpPlan website.

Income Protection means you still get paid monthly if you're off work
long-term due to illness or injury.

Most of us think we're covered if we're off work ill or injured.
But that's not always the case.

The US courts discredited Unum's "non-medical" model for assessing
medical conditions. Unum was heavily fined in all the US States,
required to undertake large numbers of reassessments and use
a "medical" model for the assessment of medical conditions.
Critics have described the "non-medical" model as pseudo-science hokum.
Critics have suggested that Unum invented this "non-medical" model
for assessment when Unum was concerned that their insurance premium income
would be far exceeded by payments in respect of specific
medical conditions.

In the UK, the judiciary consider cases on a case by case basis.
Appeals can be made on points of law and it is at this stage that precedents
can be set. Clearly a company in such a position as Unum would not be keen
to appeal as many claimants might be able to use any precedent set to further
their previously declined claims to the detriment of Unum's financial position.

Unum are selling to employers as the contract is between the employer
and employee. If an employee disputes the results of the assessment,
the employee could sue the employer and the employer may sue Unum.
A court action, especially as many would say the employer is defending the indefensible,
may bring the employer into disrepute and result in considerable adverse publicity.
Unum is in a win-win situation. Unum receives the premiums, denies the claim
and thus does not need to payout. The employer is the "patsy".

September 2000 - Til Death Us Do Part

Edited, for clarity, extracts from a Personnel Today article reprinted December 2011.

Permanent health insurance can be an important tool for recruiting and retaining
senior executives. But beware - the advantages could be far outweighed by huge
penalties if employers fail to heed its hidden dangers.

The rights of employees under PHI schemes were further defined in the subsequent case
of Villella v MFI Furniture Centres, 1999, IRLR 468.

Unum accepted the severity of my client's condition (severe heart condition).
However Unum declined his claim on grounds that he could perform sedentary work, and
that the physical demands of his job were minimal.

Despite the medical evidence, Unum continued to resist the claim, even in the face
of requests and representations from my client's MP. There was therefore no alternative
but to sue. Two weeks before the trial my client died. Despite this Unum continued to
resist the claim...

Employers should therefore be warned. One of your staff may have a persuasive claim for
PHI benefits. However, if insurers decline the claim then the employee will be entitled
to sue you for those benefits.

Hansard

Commons 21 Mar 2011 - Work Capability Assessment

Stephen Lloyd: To ask the Secretary of State for
Work and Pensions whether his Department has engaged Unum in the (a) design and
(b) administration of the (i) work capability assessment and (ii) appeals process. [46816]

Chris Grayling: The work capability assessment was
developed in 2008 with the assistance of technical working groups. As you may be aware,
the Government consult widely with stakeholders and sources of public and private sector
expertise, to ensure that its policies are evidence-based.
Two Unum employees, a doctor and an occupational therapist,
were invited to join the technical working group that carried out the review of the
personal capability assessment. As with all members of the technical working group
they were appointed as recognised experts in benefit assessment and in supporting return
to work for people with disability.

I can confirm that since the initial review of the personal capability assessment as part
of the technical working groups, that representatives of the company, Unum, have not been
involved in either the administration or review of the work capability assessment.

The Department of Work and Pension has also not engaged with Unum in the design or
administration of the appeals process.

Unum Evidence to the Work and Pensions Committee

These are extracts from evidence provided by Unum to the
UK Parliament Work and Pensions Committee.

Unum succeeds in influencing the UK Government.

"We endorse the name of the benefit being changed to the Employment and Support Allowance.
We have long argued for this change as it sets the tone for how the benefit is perceived."

Unum is the organ grinder.

"Unum, the UK's largest group income protection insurer
Unum(www.unum.co.uk) and
Unum Work Matters(www.unumworkmatters.co.uk),
has agreed to host in London, England the 2012 International Forum on Disability Management
(IFDM) - the tenth anniversary of the conference. Founded by NIDMAR, the IFDM is now under
the auspices of the International Disability Management Standards Council (IDMSC),
an international multi-stakeholder agency aimed at reducing the human, social and
economic costs of disability in the workplace."

Unum does not want some of its work to become public.

"The advisors upon whom NICE relies have been shown to have undeclared vested interests"

December 2002

Memorandum submitted by UnumProvident (EDP 03)

EXECUTIVE SUMMARY

UnumProvident has been operating in the UK for over 30 years, and is the UK's leading provider
of income protection insurance. At the end of 2001 in the UK alone, it protected over 737,000
lives and paid benefits to people with disabilities totalling some £116 million. As such, it
brings a unique perspective to assist the Committee in its inquiry.

UnumProvident believes that the current welfare, tax and benefits systems can make it difficult
for disabled people to return to work. They are overly complex, can provide strong disincentives
for disabled people to look for work, for example in terms of structure, payment criteria and
terminology, and are in need of radical reform.

April 2003

Unum view on JobcentrePlus and Support for Disabled People

JOBCENTRE PLUS AND SUPPORT FOR DISABLED PEOPLE

49. Support for job retention programmes to prevent people from dropping out of the labour market
due to failing health or the onset of a disability is widespread. UnumProvident suggests that
the failure to offer rehabilitation services is directly linked to the increase in the numbers
of people claiming Incapacity Benefits. The Employers Forum on Disability say, "If we are to
minimise the numbers of people moving onto disability related benefits in the future and if
we are to minimise the risks employers associate with hiring disabled people now, we need to
put the provision of retention related services and employer retention related policy much
higher up the policy agenda."

12. Most members of the Group believe greater communication of best practice will create
a wider trickle down effect across the country. Job Centre Plus might be the best mechanism
to co-ordinate such activity. UnumProvident has worked together with the Department for Work
and Pensions and Job Centre Plus to create "The Knowledge" a best practice guide for employers.
New Beginnings would like to see more of this kind of activity.

MEMBERS OF THE NEW BEGINNINGS ADVISORY GROUP INCLUDE:-

B&Q Business in the Community
CBI The Cooperative Bank
Disability Alliance Disability Rights Commission
Employers Forum on Disability HSBC
The Institute of Directors Scottish Power
The Shaw Trust Swiss Re
UnumProvident Barclays Bank

October 2005

Memorandum submitted by UnumProvident

At the end of 2004, UnumProvident protected over 2.1 million lives through more than 19,800
schemes. During 2004 we paid total benefit claims of over £249 million-of which more than
£177 million related to income protection claims.

Our commitment to the wider world of disability and employment is shown by our prime mover
support for "Beginnings"[38] and in 2004 our long-term interest in vocational rehabilitation
was demonstrated by the appointment of Prof Mansel Aylward to be the first director of the
UnumProvident Centre for Psychosocial and Disability Research at Cardiff University.
The Centre's research will lead to a better understanding of what makes people incapacitated
and how to prevent and support disabling incapacity to help people return to work after illness.

3. THE EXPERIENCE OF SICK AND DISABLED PEOPLE

(a) Including: the experience of those who have taken part in different aspects of the
Pathways to Work pilots; barriers in accessing support offered through Pathways; awareness
of the support available; and views on further reform

(b) Are people with different disabilities and health conditions, in both pilot and non-pilot
areas, given appropriate support by Jobcentre Plus? Is there a tendency to help those perceived
as closer to the labour market?

(c) How will the reforms help those who are not able, or not yet ready, to work?

No Comment.

4. SUPPORT FOR SICK AND DISABLED PEOPLE TO MOVE BACK INTO WORK

(a) Can the reformed systems support those with variable and manageable medical conditions,
or those who are able to work part-time? Are those with mental health difficulties adequately
supported?

(b) Does the Condition Management Programme provide the right level of support?

No Comment.

5. INVOLVEMENT OF HEALTHCARE PROFESSIONALS

(a) Has Pathways successfully worked with healthcare professionals, including GPs,
particularly in rehabilitation initiatives such as the Condition Management Programme?
How can healthcare professionals be further engaged in the reform of the incapacity
benefits system?

May 2006

Supplementary memorandum submitted by UnumProvident following the
publication of the Welfare Reform Green Paper

In 2004 Professor Mansel Aylward was appointed to be the first director of the UnumProvident
Centre for Psychosocial and Disability Research at Cardiff University.

3. We endorse the name of the benefit being changed to the Employment and Support Allowance.
We have long argued for this change as it sets the tone for how the benefit is perceived.

6. Our extended experience in this field has shown us that the correct model to apply when
helping people to return to work is a bio-psychosocial one. This incorporates elements of
helping the individual deal with any sickness/illness (bio), motivating them and providing
them with the necessary support/advice/information to get back into employment (psycho),
and fully understand the social setting of their disability/lack of capacity (social),
which can incorporate wider pressures upon them (eg childcare) and employer perceptions
of certain conditions.

8. As a private provider, UnumProvident has been working on solutions to this capacity
dilemma-which will affect both sectors. In 2005 when we acquired the UK licence for potential
solution for this. A programme has been developed by a non-profit organisation in Canada,
known as the National Institute of Disability Management and Research (NIDMAR www.nidmar.ca), and consists
of Disability Management (DM) Audit Training and DM certification programmes.

20. We would therefore suggest the trialling of a "Functional Restrictions Pad" instead.
This could be modelled on the PCA, and would highlight the activities that the individual
can do without harming themselves or others...GPs should highlight the therapeutic nature
of work.

21. It is known paradox that despite the vast advances in medical treatments in the later
half of the 20th century that there is a huge increase in people who are considered too ill
to work. This rise in incapacity has taken place from the 1980s onwards and is seen in all
developed countries. It cannot be easily explained in medical terms. Clearly the increase
in illness is a complex social and psychological problem and definitely not imaginary.
The biopsychosocial model of disability not only explains this part of this phenomenon,
but also suggest how best to manage it.

22. Managers need to understand that very few illnesses actually cause complete incapacity
and that waiting until a member of staff is fully recovered from an illness or injury can be
the very worst thing they can do. Similarly, appearing to question the reasons behind an
absence can be very counterproductive and unnecessarily confrontational. Adopting an enabling
approach seeking to overcome barriers to work is very much more effective.

24. At UnumProvident we have a non-medical, enabling model of rehabilitation and we are
working with our partners at the UnumProvident Centre for Psychosocial and Disability
Research at Cardiff University to better understand what places people at risk of long-term
or chronic illness. Further information about this model can be made available to the committee.

March 2007

Evidence submitted by Professor Malcolm Hooper (NICE 07)

1. This memorandum relates to the work of NICE in one specific area, namely its Guideline on
the management of adults and children with Chronic Fatigue Syndrome/Myalgic Encephalomyelitis
("CFS/ME") currently in preparation, a draft of which was issued on 29 September 2006.

4. The incidence of ME/CFS is rising alarmingly. In order of insurance costs, one of the major
medical insurance companies (UNUM Provident) reported in 1993 that ME/CFS came second in the
list of the five most expensive chronic conditions, being three places above AIDS.
In August 2004 the same company issued a Press Release reporting a 4,000% (four thousand)
increase in claims for symptom-based syndromes, including ME/CFS. No other disease category
surpassed these rates of increase. UNUM's "CFS Management Plan" states: "UNUM stands to
lose millions if we do not move quickly to address this increasing problem". The latest
estimate (January 2007) of the economic impact of ME/CFS in the US is between
$22-$28.6 billion annually; in Japan it is $10 billion annually.

14. The advisors upon whom NICE relies have been shown to have undeclared vested interests:
These psychiatrists and their adherents are heavily involved with the medical insurance
industry, including UNUM Provident, Swiss Life, Canada Life, Norwich Union, Allied Dunbar,
Sun Alliance, Skandia, Zurich Life and Permanent Insurance, as well as the re-insurers
Swiss Re, at which Peter White is Chief Medical Officer. For the way in which these
psychiatrists deal with ME/CFS claims,
see www.meactionuk.org.uk/Notes_on_the_Insurance_issue_in_ME.htm.
For an exposition of their commercial conflicts of interest in relation to the Department
of Work and Pensions,
see www.meactionuk.org.uk/Obs_on_DLA_ Handbook_for_Gibson.html.

As an example this is from Form 10-Q (for the quarterly period ended June 30, 2011)
Page 61 Unum UK segment:

In the 6 months to June 2010 persistency was 90.8%.
In the 6 months to June 2011 persistency was 85.0%.

It is pleasing to note that "Group Long-term Disability" Insurance
persistency is falling. Increasing numbers are not renewing.
A reasonable person might suggest UK employers are now better informed
of Unum and are staying clear.

Unum UK (extracts from US company filling;
UNM 10-Q filed April 30, 2009 and UNM 8-K filed April 29, 2009).

Unum UK includes insurance for group long-term disability, group life, and individual
disability products sold primarily in the United Kingdom through field sales personnel
and independent brokers and consultants.

Unum UK Financial

Our reporting segments are comprised of the following: Unum US, Unum UK, Colonial Life,
Individual Disability – Closed Block, and Corporate and Other.
Measured as a percentage of consolidated premium income for the year ended December 31, 2009,
premium income was approximately 65.2 percent for the Unum US segment, 9.2 percent for Unum UK,
13.6 percent for Colonial Life, and 12.0 percent for the Individual Disability -
Closed Block and Corporate and Other segments combined.

The Unum UK segment includes group long-term disability insurance, group life products, and
individual disability products issued by Unum Limited and sold primarily in the United Kingdom
through field sales personnel and independent brokers and consultants.
Premium income for this segment totaled $686.1 million in 2009,
or £438.7 million in local currency.

Unum UK reported operating income of $62.3 million in the first quarter of 2009,
a 26.1 percent decrease compared to $84.3 million in the first quarter of 2008.
In local currency, operating income for the first quarter of 2009 increased 1.6 percent,
to £43.3 million from £42.6 million in the first quarter of 2008.

The benefit ratio in the first quarter 2009 was 53.3 percent, compared to 57.3 percent
in the comparable quarter in 2008, reflecting a lower rate of claim incidence in the
group long-term disability line, which was partially offset by an increase in incidence
in the group life line. Premium income decreased 32.3 percent to $163.0 million in the
first quarter of 2009, compared to $240.6 million in the first quarter of 2008.

In local currency, premium income decreased 6.7 percent to £113.5 million in the first
quarter of 2009, compared to £121.6 million in the first quarter of 2008.
Premium persistency in the group long-term disability line of business was 90.8 percent
in the first quarter of 2009, compared to 84.5 percent for the comparable period in 2008.
Premium persistency in the group life line of business was 74.5 percent for the first
quarter 2009, compared to 84.3 percent for the first quarter 2008.

Sales increased 4.8 percent to $19.6 million in the first quarter of 2009, compared to
$18.7 million in the first quarter of 2008.
In local currency, sales for the first quarter of 2009 increased 44.7 percent to
£13.6 million, compared to £9.4 million in the first quarter of 2008.

Unum Decline

Unum appears to be retreating from target markets.
It seems likely that in the US a cause for this is litigation and fines which
in turn has caused the reputation of Unum to suffer.
This adverse publicity is known in the UK.
In addition Unum's attempts to influence the Government
to attack the Welfare State, have achieved some success.
The name of Invalidity Benefit has been changed.
Benefit payments have been kept low.
Unum has spent a lot of resources so that Unum's products of dubious merit
are easier to sell.

Unum pulls out of individual income protection - March 2012

Changes to Unum's income protection offer
published by Unum March 2012.

Income protection specialist, Unum, has signalled its commitment to focusing on
the employer-paid benefits market with the removal from sale of its Individual
income protection products. It is retaining its market-leading Executive income
protection offering, which is an employer paid product that will be offered alongside
its award-winning Group products.

"We believe the workplace is the best place for workers to get income protection,"
comments Marco Forato, Chief Marketing Officer. "It makes cover more affordable
and also enables individuals with pre-existing conditions or high risk people to
get cover they may not be approved for with an individual policy."

"While some advisers do specialise in the SME segment, there are over a 150,000
companies in the UK with less than 50 employees and more often than not they don't
get the expert support they need. Through their existing relationships with small
business owners and directors, who already understand the value of workplace IP
through their own Executive policy, IFAs could easily step in and fill this gap."

Forato continues: "In the world of RDR and auto-enrolment, the employer-paid market
is a real growth opportunity for Advisers. We will partner with Advisers who have
relationships with small business decision makers through our Executive product,
helping them bring Group income protection into their discussions."

Unum's existing Personal, Primary and Essential Ability Cover product policyholders
will continue to be supported by Unum's market-leading claims management and LifeWorks
support services. The products will be closed to future sales from 2nd March,
although Unum will honour all valid quotations previously issued, provided the
completed application is received by 30 March 2012.

FT Advisor reported the above Unum new release in an article
by Marc Shoffman published 8 March 2012

Unum pulls out of individual income protection

...Mark Myers, chief executive of British Friendly, said: "We are very disappointed
to see a high quality provider leaving the individual market. Even though they were
a competitor we loved their recent adverts, which demonstrated how important IP
is to protecting the things that matter most."

Minesh Patel, owner of London-based EA Financial Solutions, said: "I am a strong
believer in income protection. I always recommend it, but clients often are resistant
to it on the basis of cost...

Unum Group fourth quarter loss reported February 2012

Unum Group reported a fourth-quarter loss of $425.4 million
reversing a profit of $225.8 million reported for the
same period the previous year.
Most of the loss came from a $561 million charge linked to
the company's exit from its long term care business.
Excluding one-off items, Unum's net operating income for the quarter rose to
$227.6 million from $208.6 million.
Revenue for the quarter ended 31 December 2011, rose to $2.6 billion
from $2.57 billion.
Unum Group stock is down 8% over the past 12 months.

Some believe that Unum underestimated the number of claims,
underestimated the cost of care and misjudged the life expectancy of their customers.
Low interest rates have limited investment income from funds expected to be
used to fund claims.

On a marketing level it cannot help Unum sales that every search
engine lists the actual experience of Unum customers.

Influential People and Unum

The following are ardent supporters of the "non-medical" model for assessing
medical conditions.

Professor Mansel Aylward

In 2004 Professor Mansel Aylward was appointed to be the first director of
the UnumProvident Centre for Psychosocial and Disability Research
at Cardiff University.

Dame Carole Black

Her support for the "non-medical" model seems rock solid.

Lord Freud

No medical knowledge but has many times strongly supported
the "non-medical" model.

In 2003, Freud had become the vice-chairman of investing banking at
a major investment bank.

In 2006, Freud was appointed by Prime Minister Tony Blair to provide
an independent review of the British welfare to work system.
His recommendations called for expanded private sector involvement in the welfare
system for substantial resources to be found to help those on Incapacity Benefit
back into economic activity and for single parents to be required to work earlier.

In 2008 he was appointed as an adviser to the Labour government when James Purnell was
appointed Secretary of State for Work and Pensions. He produced a white paper
which would require most people receiving benefits either to participate in some form
of employment or prepare formally to find work later.

In 2009, Freud joined the then opposition Conservative Party.
He was given a life peerage as Baron Freud, of Eastry in the county of Kent, and
became a shadow minister for welfare in the House of Lords.

The Coalition Government appointed Lord Freud as a Parliamentary Under Secretary
of State for Work and Pensions.

A BBC article claims Freud was involved in piecing together extremely complex
deals such as the flotations of Eurotunnel and EuroDisney, which cost investors
millions, and the financing of the Channel Tunnel rail link. Eurotunnel opened
in May 1994 one year behind schedule and 2 billion GBP over budget.
Freud later admitted the deal was a "shambles" and that he had "successfully
sold the market a pup".

Lord Freud reassures

10 March 2011 - Question - Autism: Disability Living Allowance

...we are committed to ensuring that it reflects the needs of all individuals effectively.
We recognise that the current assessment criteria for disability living allowance can
favour physical impairments and do not always fully reflect the needs of disabled people
with mental, intellectual, cognitive and development impairments, including autism...

...One of the things that we want to get absolutely right is how we look after the most
vulnerable. The default position is that we would like to see people face to face, but
where that is not realistic, helpful or appropriate we will not be doing so. We will
also encourage people, autistic people as well as others, to bring a carer, a family
member or a professional with them so that we get the best evidence-based result that
we possibly can.

Entitlement to employment and support allowance (ESA) is based on an assessment of
functional capability, not on medical condition or diagnosis....

...So, for example, a decision on entitlement for a customer claiming ESA on the basis
of a mental health condition would be based on their ability to carry out the range of
activities assessed by the work capability assessment. It is also important to note that,
where someone has more than one diagnosis or disabling condition, only the predominant
one is currently recorded...

Entitlement to employment and support allowance (ESA) is based on an assessment of
functional capability, not on medical condition or diagnosis....

Asked by Lord Morris of Manchester

To ask Her Majesty's Government what is their response to Macmillan Cancer Support's estimate
that their proposals to limit contributory employment and support allowance (ESA) to 12 months
will result in 7,000 cancer patients losing up to £94 per week in benefits, and that those
whose partners earn £7,500 or more a year could lose their ESA altogether.[HL11727]

Lord Freud: The department has carefully considered the position of people with a range of
serious and life threatening illnesses-including cancer-in relation to the benefit system.
We do not aim to reduce the levels of support for the most severely ill or disabled people
but it is clearly important that we ensure it is well targeted, is fair to those on low pay
and that the right money goes to the right people.

Following an internal review we have recently made changes to the work capability assessment
(WCA) so that more individuals undergoing certain chemotherapy treatments will automatically
be placed in the support group without the need for an assessment. Those in the support group,
including many cancer patients, will not be affected by the time-limiting measure.

People will still be able to claim income-related employment and support allowance (ESA)
subject to meeting the conditions of entitlement. Access to income-related ESA is not affected
by this measure. This measure will not leave people destitute-only those who have alternative
resources will not qualify for income-related ESA. Typically they would have a partner in
full-time work or have savings in excess of £16,000 in order not to qualify for income-related ESA.

Dependent on individual circumstances, a person may be able to claim a number of benefits,
for example housing benefit, council tax benefit, pension credit and tax credits. Additionally,
those who do not qualify for income-related ESA will still be able to claim ESA on a
"credits only" basis so that they can maintain their national insurance contribution record.

A claimant will also retain any entitlement to disability living allowance, provided they
continue to meet the qualifying conditions. Not all those affected with cancer will be
financially worse off as a result of this measure as some will be fully or partially
compensated by income-related ESA.

Additionally, Professor Harrington, as part of his second independent review, asked
Macmillan Cancer Support to look in detail at how the WCA assesses people with cancer and
to provide him with recommendations for further improvements. We have recently received
these recommendations from Professor Harrington. We are considering them carefully to
understand whether they will improve the assessment further for individuals with cancer.
We will come forward with any proposals shortly.

We are determined that the social security system should support people who are diagnosed
with cancer in the most sensitive, fair and appropriate way and have been working with
Macmillan Cancer Support and others to achieve this.

To ask Her Majesty's Government (a) on how many occasions they have met officials
from UNUM Provident; (b) on how many occasions officials from UNUM Provident have
been members of advisory committees or working groups of the Department for Work
and Pensions or the Department of Health, and (c) which other insurance companies
have been involved in similar activities.[HL13073]

Lord Freud:
An extensive search of recent records within the department was carried out following
receipt of your question, and details of meetings between department officials and
representatives of UNUM Provident, details of membership of advisory committees or
working groups, and details of similar activity with other insurance companies,
are listed below. However, it should be noted that there are approximately 100,000
officials within the department
and it would not be possible, except at disproportionate cost, to ask each of them
whether they have engaged in any such discussions.

(a) on 14 February 2011, UNUM Provident officials met with officials involved in
the independent review of sickness absence in Great Britain to discuss a research paper.
In February 2011, the Government commissioned the independent review to explore the
current sickness absence system, and examine whether the costs associated with
sickness absence are appropriately shared between the state, individuals and employers.
The independent review is being jointly led by Dame Carol Black and David Frost CBE;
and on 18 October 2010, a representative from UNUM Provident, who was part of a
delegation from the UK Rehabilitation Council, met with the Minister for Welfare Reform
and department officials.
A full list of ministerial meetings with external organisations is available at
www.dwp.gov.uk/publications/corporate-publications/ministers-meetings-overseas.shtml.

The Minister for Welfare Reform has also attended a round table on 5 October 2010
at the Conservative Party Conference which was jointly hosted by Demos and UNUM.

(b) two working groups were set up in 2006 to review the personal capability assessment
for incapacity benefit. One of these groups reviewed the physical descriptors within
the assessment, and of the seven meetings for which we have a record there were four
meetings which the UNUM Provident representative definitely did not attend; the other
looked at the descriptors which assessed mental function, and of the five meetings
for which we have a record, the UNUM Provident representative was not recorded as being
absent from any of them; and Jack McGarry, CEO of UNUM UK, was nominated to sit on
the independent review of sickness absence in Great Britain expert panel by the
insurance industry body.

(c) As part of the evidence-gathering process for the independent review of sickness
absence in Great Britain, department officials, as well as the independent reviewers,
have met with or had contact with a number of insurers in the course of this work-the
Association of British Insurers, Aviva, BUPA, Genworth Financial, Legal and General,
SwissRe, and GRiD-Group Risk Development.

Ministers and officials meet with representatives of the insurance industry on a
regular basis to discuss issues arising from compulsory employer liability insurance.

Lord Kirkwood of Kirkhope

A previous Chair of the Parliamentary Select Committee on Work and Pensions,
Lord Kirkwood of Kirkhope, is listed in the House of Lords Register of Interests
(Session 2006-2007) as the Chairman of the Unum Customer Advisory Panel for which
he received payment from Unum and additional payments for other work for Unum.

Unum and Press Articles

James Purnell's reforms of incapacity benefit are inspired by a US company with
vested interests and a murky record. Now, that's really sick

... In 1994, the Tory government hired John LoCascio, second vice-president
of giant US disability insurance company, Unum, to advise on reducing the numbers
successfully claiming IB.
He joined the "medical evaluation group".
Another key figure in the group was Mansel Aylward.
They devised a stringent "all work test".
Approved doctors were trained in Unum's approach to claims management. ...."

...In 1999, New Labour introduced its first Welfare Reform Act.
All new claimants had to attend a compulsory work focused interview.
Mansel Aylward, now chief medical officer of the DWP, devised a new personal
capability assessment (PCA).
The emphasis was no longer on entitlement, but on what a person is capable of doing....

...Unum has built up its influence in Britain.
In July 2004, it opened its £1.6m Unum Centre for Psychosocial and Disability Research
at Cardiff University.
The company appointed Mansel Aylward as director following his retirement from the
DWP in April...

...The aim of the centre is to transform the ideology of welfare and so help
develop the market for Unum's products. In 2005, the centre produced a monograph
The Scientific & Conceptual Basis of Incapacity Benefits (TSO, 2005)
written by Aylward and his colleague Gordon Waddell.
It provides the framework for the 2006 welfare reform bill.
Its methodology is the same one that informs the work of Unum...

...California Insurance Commissioner John Garamendi described Unum as,
"an outlaw company.
It is a company that for years has operated in an illegal fashion"...

...This is the company that has played a leading role in shaping welfare reform
in Britain. It has promoted the ideas behind the new work capability assessment.
The more stringent the assessment, the more people fail it or fear failing it, and
so the larger the potential market in private disability insurance.